FEHBP Final Rule on Provider Sanctions
Client Alert | 1 min read | 03.08.04
The Office of Personnel Management ("OPM") has issued a final financial sanctions rule for health care providers participating in the Federal Employees Health Benefits Program ("FEHBP"). Two categories of financial sanctions are established by the March 3 rule: assessments, which are intended to recognize losses, costs, and damages incurred as the result of a provider's wrongful conduct, and civil monetary penalties, which are lump-sum amounts that, while computed by reference to improper claims, are intended principally to deter future violations. The bases for financial sanctions are (1) fraudulent or improper claims; (2) false or misleading statements in or about claims; and (3) failure to provide claims-related information that is required by law to be disclosed. Sanctions may be imposed only for violations that directly involve FEHBP enrollees, carriers, or funds. The final rule sets forth the procedures for imposing, determining the amount, and collecting financial sanctions, as well as providers' right to contest and appeal the imposition of financial sanctions. The March 3 final rule also clarifies the circumstances under which payments may be made from FEHBP funds to suspended providers. This rule, along with the rule governing suspension and debarment of FEHBP providers, implements the administrative sanctions enacted by the Federal Employees Health Care Protection Act of 1998 (Pub. L. 105-266).
Insights
Client Alert | 6 min read | 02.24.26
Artificial Intelligence and Human Resources in the EU: a 2026 Legal Overview
The year 2026 marks a major regulatory turning point for European companies using or considering the use of artificial intelligence in their human resources (HR) processes. The Regulation (EU) 2024/1689 on artificial intelligence (the AI Act) is entering a critical implementation phase, while the European Commission's "Digital Omnibus" package will clarify several obligations and modify certain deadlines.
Client Alert | 3 min read | 02.24.26
DOJ v. OhioHealth Confirms Antitrust Enforcers’ Continued Focus on Health Care Markets
Client Alert | 4 min read | 02.24.26
Client Alert | 4 min read | 02.24.26
State-Level Merger Control Grows: California Joins “Mini-HSR” Trend with Senate Bill 25
